Thank you for the opportunity to comment on the V1.0 draft sustainable food system. We have some comments that we will ask you to take into consideration:
In 2014 the CFS gave the advice to make fish a visible, integral element in food security and nutrition strategies, policies and programmes. CFS also invited FAO to make explicit reference to fish resources and aquaculture as vital in combating hunger and securing nutritious food for everybody in all relevant documents on agriculture, food security and nutrition. Fish contains high levels of important nutrients that are not commonly found in other foods. It is a good source of proteins, very long-chain omega-3 fatty acids, vitamin D, vitamin B12, selenium and iodine. These nutrients are of greatest public health concerns. Food security is not just about enough food but the right kind of food. We have to remember that aquatic food can be a part of the solution. Still, aquatic food is often left out of relevant work, including in some of the text in this V1.0 draft. Reference is made to the CFS HLPE report on Sustainable Fisheries and Aquaculture for Food Security and Nutrition, which we think should be looked into and referred to in this work: http://www.fao.org/3/a-i3844e.pdf
Food systems also includes aquatic food systems. In UN the word "agriculture" is defined to include crops, livestock, forestry, fisheries and aquaculture. The document actually mention a sort of similar definition, but we have to wait until we get to the box at page 44. The first time fish is mentioned is at page 17. Fisheries and aquaculture are included in the text before that, however hidden in the word agriculture. When people read the word "agriculture", eg page 6 "the area of food and agriculture", chances are slim that they will think of fisheries and aquaculture. This is unfortunate, and may be one of the reason that aquatic food, fisheries and aquaculture often are left out of relevant texts and work. Hence we would ask you to look through the document and see if you could do as CFS has recommended, make fish visible. Eg add a footnote were the term agriculture is used the first time, which states that in this document the term “agriculture” includes crops, livestock, forestry, fisheries and aquaculture. Alternatively specify in the text where appropriate. Another alternative is to change the wording "food and agriculture" to "food and food production". This do not exclude fisheries and aquaculture semantically. Having said that, we are also happy to see that the definitions on food systems, page 8, uses the words food, food production etc. Such words are related to all types of food, both from land, oceans and inland waters.
With a reference to the fact above, we do question the footnote no 24 at page 11 which says: "While specific definitions are likely to vary from country to country, the food and agriculture sector typically comprises: i) entities that are engaged in growing crops, raising livestock and harvesting other animals as well as timber; ii) entities that transform agricultural products into food and beverage products for intermediate or final consumption (including packaging, etc.); iii) wholesalers and retailers (including transportation, etc.). " Where is the fish?
Sustainable food systems for healthy diets is recognized as one of the six pillars of the UN Decade of action on Nutrition. Thus Norway has initiated a global action network Sustainable Food from the Oceans and Inland Waters for Food Security and Nutrition under the umbrella of the Nutrition decade. Taking a holistic approach from the healthy ocean to the healthy consumer, including cross sectorial expertise and paying attention to the elements of food security (sufficient, safe, nutritious, dietary needs, food preferences and leaving no one behind). We believe that responsible fisheries and aquaculture development will be one of the keys in achieving the sustainable development goals (such as goal no 1, 2, 3, 8, 12. and 14 to mention some). We would like to ask why SDG 14, life below water, is not mentioned at page 27? Life on land SDG 15 is. The environment where we grow our food, both on land SDG15 and below water SDG14 is important. Why just mention one? Healthy sustainable environment both on land and in waters are important to produce sufficient and safe food.
We are happy to see that in the later part of the document, there are several references related to aquatic food, but it would be even better if it was made clear earlier in the document that sustainable food systems also includes aquatic food. It deserves to be more visible at the beginning. We would also appreciate if you looked through the text to make sure that aquatic food systems are not excluded by the formulations.
Best regards,
Anita Utheim Iversen
Senior Adviser
Ministry of Trade, Industry and Fisheries
Anita Utheim Iversen